Misconceptions About Security Information Sheets

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At the present time, we now have entry to extra data within the palms of our palms than at another time in historical past. Whereas that is often an important factor, it may additionally typically grow to be an issue when the data we’re receiving after which sharing is not full, is lacking context, or is just misinterpreted.

These conditions are what usually result in standard misconceptions and at instances, they are often fairly damaging. Surprisingly, one place the place many misconceptions lurk is with how sure environmental, well being, and security rules are understood.

A number of such misconceptions might be discovered throughout the understanding of how Security Information Sheets or SDS are speculated to be managed. On this article, we’ll discuss three such misconceptions surrounding Security Information Sheets and offer you a number of assets to examine the data out for yourselves.

#1: Each chemical will need to have an accompanying Security Information Sheet

It seems like this ought to be correct, would not it? From what we find out about managing chemical compounds within the office and the requirement to supply a office that is freed from acknowledged hazards it will appear believable for Security Information Sheets to be required for each chemical within the office. However, surprisingly, that is not at all times the case.

When the employer can adequately display that sure merchandise which meet the definition of a “shopper product” by the Shopper Product Security Act are getting used the identical manner {that a} shopper would use them, they’d fall beneath the buyer merchandise exemption present in 1200( b)(6)(ix) of the Hazard Communication Commonplace. However what does that imply precisely?

In each office, there are often chemical compounds being utilized in the identical manner {that a} common shopper would use them. For instance, let’s take a look at the abnormal lavatory cleaner you’d purchase within the cleansing aisle of a giant chain retailer. When the conventional shopper buys a toilet cleaner, they will purchase a bottle or two and they will use it to wash their loos. Whereas each shopper is a bit totally different with how usually they clear their loos, there is a frequent understanding that goes together with the usage of this product. 99% of shoppers aren’t going to spend a number of hours a day utilizing this product to wash their loos nor are they going to make use of this product to wash issues exterior of the toilet.

If an employer buys a bottle or two of this identical lavatory cleaner after which makes use of it to wash their very own loos, they actually needn’t have a Security Information Sheet for it as a result of the publicity to the chemical compounds within the lavatory cleaner are the identical as what a typical shopper would expertise. Now, if that very same employer buys a case of that loo cleaner after which makes use of it to wash loos for 8 hours a day or makes use of it for some off label use to wash gear components, then the publicity to the chemical compounds within the lavatory cleaner are not “typical” and it turns into a hazard that requires an SDS.

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Primarily, if an employer offers a product and might present that the product is getting used within the office for the aim supposed by the producer and/or importer and in the identical frequency and length of use in order that the chemical publicity isn’t larger than the “vary of exposures” that might fairly be skilled by shoppers, then an SDS isn’t usually wanted. Sadly, there’s not a easy, clear-cut set of necessities for this exemption and it is fully as much as the employer to find out what merchandise, if any, match into this class and due to this, many employers select to not acknowledge this exemption.

#2 Each SDS have to be stored on file for at the very least 30 years

When you’re an employer confronted with the prospect of getting to retailer each SDS for a interval of 30 years and also you’re questioning how on earth you are going to try this, you possibly can relaxation straightforward since you do not usually must . In truth, actually the one time data from an SDS have to be saved for a particular size of time is after an worker publicity happens and even then, solely components of the SDS are wanted. These necessities are particularly addressed in 1910.1020(d)(1)(ii) of the Poisonous and Hazardous Substances normal and basically state that after publicity, solely the chemical title of the substance and the place and when it was used have to be retained for at the very least 30 years. Let us take a look at an instance of what we imply.

Suppose as a part of an organization’s manufacturing processes they use a substance that is thought-about to be a “dangerous bodily agent” and suppose in the future a employee inhales that dangerous bodily agent and turns into ailing or injured. This case would meet OSHA’s definition of an “publicity” and the employer would then be required to maintain at the very least the title of the substance the employee was uncovered to in addition to when and the place it was used on file for at the very least 30 years. Usually talking, the employer might be going to create a file for this employee the place all of the publicity data (together with the SDS), any remedy data, and/or communications concerning the publicity are maintained. Whereas some employers might not select to maintain the precise SDS itself and solely maintain the required data from that SDS, others might wish to guarantee they’ve further details about that chemical substance if they need to ever want it.

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So, for those who have been involved about having to retailer all of the Security Information Sheets you obtain for 30 years, relaxation assured you do not have to—until your organization has an inside coverage requiring it.

#3 Storing SDS electronically & “What occurs when the facility goes out?”

We have saved this one for final as a result of over time this query has advanced a bit because of developments in know-how. Initially, the one possible technique of holding Security Information Sheets (known as MSDS again then) was to maintain them in paper kind. Some employers selected to try this by utilizing binders and others selected to have a central location with a file cupboard or one thing comparable. Again then, the reply to the query “What occurs when the facility goes out and also you want details about a chemical?” was easy—if the facility goes out, you open a binder or file cupboard and use a flashlight to seek out the data you want.

As computer systems have grow to be a extra broadly used software for chemical administration, the query of how employers can present entry to chemical security information throughout an emergency and nonetheless meet OSHA’s necessities for “barrier-free, prepared entry” has been requested quite a few instances—and OSHA’s response has remained largely unchanged. When you overview OSHA’s Letters of Interpretation about this topic, it doesn’t matter what kind of know-how is being requested about, OSHA falls again on the identical factor each time—that irrespective of the state of affairs, employees will need to have barrier-free, prepared entry to chemical security data of their work areas, no matter the place these work areas could be.

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OSHA makes it very clear that whether or not it is throughout emergencies, whereas employees are on distant job websites, and/or when employees should work between a number of job areas, if the know-how getting used to provide chemical security data is proscribed due to location or state of affairs, a backup have to be supplied. Moreover, no matter backup is chosen, it should additionally present a barrier-free and instant means for employees to entry the wanted data. Let us take a look at a number of examples of the appropriate choices we have supplied within the desk under.


potential conditions

Software program or Digital Database

  • Throughout emergencies the place energy is affected
  • When employees journey between areas
  • When employees carry out work at distant areas

Acceptable Backup Choices

Paper Copies (usually up to date)


Backup Laptop computer + Detachable Drive

  • Supplied in firm autos
  • Supplied to employees who should journey between websites and/or to distant websites
  • Supplied in binder/cupboard the place all employees can entry on the principal job location
  • Could solely be a backup to the first system if the data is supplied instantly through phone & if the SDS is supplied as quickly as potential afterwards
  • Separate laptop computer (stored absolutely charged and/or with a completely charged spare battery)
  • Detachable drive (thumb drive/bounce drive, and so on.)

It is necessary to notice that no matter how an employer decides to adjust to the usual, data on the first and backup strategies for accessing Security Information Sheets have to be supplied in an employer’s written Hazard Communication Program.

Consider Recurrently

Each employer needs to supply their workforce with the suitable instruments to make sure they’ve the data they want once they want it. To do that successfully, employers have to contemplate all various kinds of conditions which may occur after which select the perfect options for his or her wants. It is a course of that ought to be completed frequently. Not solely do wants change, however what was as soon as an appropriate resolution would possibly not be and the worst time to determine this out is throughout an emergency.

When you’re within the strategy of re-evaluating the way you’re at present managing your Security Information Sheets and want to hear about our new options for managing SDS, begin a free trial right now!

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